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You must consider an injury or illness to be work-related if an event or exposure in the work
environment discernibly caused or contributed to the resulting condition, or if an event or
exposure occurring in the work environment is a discernable cause of a significant aggravation to
a preexisting injury or illness. The work event or exposure need only be one of the causes of, or
contributors to, the resulting injury or illness; it need not be the sole or predominant cause or
contributor. Work-relatedness is presumed for injuries and illnesses resulting from events or
exposures occurring in the work environment, even if the injury or illness does not have a clear
connection to a specific work activity or is not occupational in nature.
Injuries and illnesses that occur at work may not have a clear connection to a specific work
activity, condition, or substance that is peculiar to the employment environment. For example,
an employee may trip for no apparent reason while walking across a level factory floor; be
sexually assaulted by a co-worker; or be injured accidentally as a result of an act of violence
perpetrated by one co-worker against a third party. In these and similar cases, the employee’s
job-related tasks or exposures did not create or contribute to the risk that such an injury would
occur. Nevertheless, these cases are work-related. The causal connection is established by the
fact that the injury would not have occurred but for the conditions and obligations of
employment that placed the employee in the position in which he or she was injured or made ill.
An injury or illness is not reportable if the injury or illness involves signs or symptoms that
manifest themselves at work but result solely from a non-work-related event or exposure that
occurs outside the work environment. See reporting exceptions listed at § 225.15.
If it is not obvious whether the precipitating event or exposure that caused or contributed to an
injury or illness occurred in the work environment or elsewhere, the employer must evaluate the
employee’s work duties and environment to decide whether one or more events or exposures in
the work environment caused or contributed to the resulting condition, or significantly
aggravated a preexisting condition. As long as the event or exposure occurred at work and is a
discernable cause of the injury or illness or is a discernable cause of a significant aggravation to
a preexisting injury or illness, the injury or illness is work-related. If an injury is within the
presumption of work-relatedness, the employer can rebut work-relatedness only by showing that
the case falls within an exception listed in § 225.15. This means that the employer must make a
determination as to whether it is more likely than not that work events or exposures were a
discernable cause of the injury or illness, or a discernable cause of a significant aggravation to a
preexisting condition. The evaluation might include consultation with an ergonomics expert as
well as a PLHCP. A review of the job description, alone, is not sufficient without reviewing all
of the employee’s collateral duties. If the employer decides the case is not work-related, and
FRA subsequently issues a citation for failure to report, the Government would have the burden
of proving that the injury or illness was work-related.
FRA Guide for Preparing Accident/Incident Reports
53
F 6180.55a
6.6.1 Interpretations on Work-Relatedness
Scenario 1:
An employer asks if an injury or illness sustained by an on-duty employee while he or she is
engaged in an activity, such as walking or bending, is considered work-related. The employer
notes that a case is presumed to be work-related if an event or exposure in the work environment
discernibly caused or contributed to the injury or illness. The work event or exposure need only
be one of the causes or contributions to the injury or illness; it need not be the sole or
predominant cause.
Response 1:
The question employers must answer is whether there is an identifiable event or exposure that
occurred in the work environment and resulted in the injury or illness. Thus, if an employee trips
while walking across a level shop floor, the resulting injury is considered work-related because
the precipitating event—the tripping accident—occurred in the workplace. The case is workrelated even if the employer cannot determine why the employee tripped, or whether any
particular workplace hazard caused the accident to occur.
The activity engaged in by the employee at the time of the injury—walking—is an “event” that
would trigger application of the presumption. Other examples of events include sneezing,
climbing, tripping, and bending down. In the absence of evidence to overcome the presumption,
the injury is work-related. Thus, in the absence of evidence to overcome the presumption, an
ankle injury caused by a trip that occurred while the employee was walking down a level
seamless hallway at work is work-related, regardless of whether the accident is attributable to a
defect in the hall. By the same reasoning, if the activity of walking down a hallway caused the
employee’s knee to buckle or to sprain the ankle, the injury is work-related. If an injury or
illness did not result from an identifiable event or exposure in the work environment, but only
manifested itself during work, the injury is not work-related. For example, if the employee had a
non-occupational event or exposure, and there is no evidence of a work-related event or exposure
that caused or contributed to the injury or illness, the injury should not be reported.
There is also the issue of whether the determination of work-relatedness is affected by an
employee’s preexisting condition. For reporting purposes, a preexisting condition is an injury or
illness resulting solely from a non-work-related event or exposure. If an employee’s preexisting
condition is worsened as a result of an event or exposure at work, the case is work-related if the
work event or exposure “significantly aggravated” the preexisting condition (i.e., discernibly
caused the case to meet any of the general criteria).
If an employee with a previous work-related injury to a body part suffers a subsequent workrelated injury of the same type to the same body part, the subsequent injury is reportable
(assuming the general reporting criteria are met) if it is a “new case” as described in this chapter.
FRA Guide for Preparing Accident/Incident Reports
54
F 6180.55a
If the subsequent injury is not a “new case,” then the railroad is required to update the previously
submitted injury or illness report if necessary.
Scenario 2:
An employee reported to work at 7:00 a.m. At 12:15 p.m., the employee reported that his toes
on his left foot started swelling and his foot started hurting. The employee wanted to go to a
doctor for evaluation.
On the first report of injury that the employee completed before he went to the doctor,
the employee indicated that the cause of the illness was “unknown.”
When answering the doctor’s question: “How did the injury occur?,” the employee answered
that the only thing he could think of was that his feet were wet all the previous day due to work
in the morning at a cooling tower. The cooling tower water is treated to remove bacteria and
then used in process operations in the plant.
The doctor described the illness/injury as foot edema/cellulitis. The doctor also diagnosed the
injury as an occupational disease, prescribed an antibiotic, and the employee missed 1 day of
work. The company sent the employee to a second doctor who said to continue using the
antibiotic. Neither doctor could state conclusively that the foot edema/cellulitis was or was not
due to the employee’s feet being wet due to work at the cooling tower. Neither doctor is a
specialist in skin disorders.
During an incident review at the site, the employee again said he did not know if his feet being
wet all day the previous day caused the injury/illness. The employee also stated that he had not
worn the personal protective equipment—rubber boots—prescribed for this task.
The company determined that this injury/illness was not work-related (did not occur in the
course of or as a result of employment), since neither physician nor the employee could state